Criminal Law

Consensual Relationship Not Rape: False Promise of Marriage Must Be Proven from Inception

Supreme Court quashes rape case, ruling that a long-term consensual relationship cannot be criminalized merely because it didn't lead to marriage. The Court emphasized that for a false promise to vitiate consent, it must be shown that the accused never intended to marry from the beginning.

Case Reference: Samadhan S/o Sitaram Manmothe vs State of Maharashtra & Another (Criminal Appeal No.5001 of 2025) Decided by: Supreme Court of India Date: November 24, 2025

❓ Question

CAN A CONSENSUAL RELATIONSHIP THAT CONTINUED FOR YEARS BE CRIMINALIZED AS RAPE MERELY BECAUSE IT DIDN'T LEAD TO MARRIAGE?

✅ Answer

NO, RELATIONSHIP TURNING SOUR DOESN'T MAKE IT RAPE. The Supreme Court has quashed rape charges against a lawyer, ruling that a three-year consensual relationship cannot be retrospectively branded as rape when it fails to culminate in marriage. The Court emphasized that for a "false promise of marriage" to constitute rape, it must be proven that the accused never intended to marry from the very beginning, not merely that the relationship eventually ended.

⚖️ Understanding the Legal Principles

🔹 Consent Must Be Vitiated from Beginning

  • False promise must be made with dishonest intention from inception
  • Mere breach of promise doesn't constitute rape
  • Relationship failure doesn't retroactively make consent invalid
  • Must prove accused never intended to marry from start

🔹 Long-term Relationship Indicates Consent

  • Three-year relationship shows voluntary participation
  • Multiple meetings and physical intimacy indicate consent
  • No complaints during relationship period
  • Complaint filed only after monetary demand refused

🔹 Misuse of Criminal Law Condemned

  • Court concerned about misuse of rape laws
  • Failed relationships shouldn't be criminalized
  • Rape laws meant for genuine sexual violence cases
  • Personal disputes shouldn't burden criminal justice system

🔹 Section 376(2)(n) Requirements

  • Requires repeated commission of rape on same woman
  • Must show absence of consent in each instance
  • Consensual relationship doesn't qualify under this section
  • Pattern of sexual assault under pressure required

📜 Relationship Timeline & Key Events

January 27, 2022

First Meeting: Complainant meets appellant (advocate) regarding maintenance case against her husband

March 12, 2022

First Physical Relationship: At Hotel Citizen after appellant's marriage proposal

September 2022

First Pregnancy: Complainant discovers pregnancy, undergoes abortion with appellant's consent

July 2023

Second Pregnancy: Gets pregnant again, pregnancy terminated

May 2024

Third Pregnancy: Another pregnancy terminated

May 20, 2024

Last Meeting: Final physical relationship at Hotel Citizen

August 2024

Monetary Demand: Complainant demands ₹1,50,000 from appellant

August 31, 2024

FIR Registered: Rape case filed after appellant refuses payment

November 24, 2025

Supreme Court Quashes Case: Court rules relationship was consensual

🧭 Your Action Plan: Understanding Consent & Relationships

📝 If You're in a Relationship

✅ Understand Genuine Consent

  • Consent must be voluntary and informed
  • Long-term participation indicates consent
  • Relationship failure doesn't invalidate past consent
  • Document relationship milestones and communications

✅ Distinguish Between Promise & Intention

  • Failed promise ≠ false promise from beginning
  • Changed circumstances don't prove dishonest intention
  • Must prove no intention to marry from relationship start
  • Keep records of marriage discussions and plans

⚖️ Key Legal Distinctions

Legal Concept What It Means Legal Consequence
Consensual Relationship Both parties voluntarily participate in relationship Not criminal, even if relationship ends badly
False Promise of Marriage Accused never intended to marry from beginning May constitute rape if consent was based on this deception
Breach of Promise Genuine intention changed due to circumstances Civil matter, not criminal offense
Relationship Turning Sour Consensual relationship that ended badly Personal dispute, not criminal case

⚖️ Protecting Your Rights in Relationships

✅ Maintain Clear Communication

  • Keep records of important conversations
  • Document marriage discussions and timelines
  • Save messages showing relationship was consensual
  • Note any monetary demands or threats

📘 Key Legal Terms Explained

Consent

Voluntary agreement to engage in sexual activity without coercion, fear, or misconception.

False Promise of Marriage

When a person makes a promise to marry with no intention of fulfilling it from the beginning, solely to establish sexual relations.

Section 376 IPC

Indian Penal Code section dealing with punishment for rape, requiring absence of consent.

Section 376(2)(n) IPC

Enhanced punishment for committing rape repeatedly on the same woman.

Vitiation of Consent

When consent is obtained through fraud, misconception, or coercion, making it invalid.

🚨 What the Supreme Court Emphasized

✅ Consensual Relationship Protected

  • Three-year relationship shows voluntary participation
  • Multiple pregnancies terminated with mutual consent
  • No complaints during relationship period
  • Complaint filed only after monetary demand refused

✅ False Promise Must Be Proven

  • Must show dishonest intention from relationship start
  • Mere relationship failure doesn't prove false promise
  • Complainant herself opposed marriage initially
  • Continued relationship despite marriage refusal

❌ Misuse of Law Condemned

  • Court expressed concern about misuse of rape laws
  • Failed relationships being given color of criminality
  • Personal disputes burdening criminal justice system
  • Genuine rape cases getting diluted

❌ Timing of Complaint Suspicious

  • FIR filed 3 months after last physical relationship
  • Immediately after monetary demand refused
  • No explanation for delay in reporting
  • No protest or complaint during 3-year relationship

💡 Core Takeaway from the Supreme Court

"The offence of rape, being of the gravest kind, must be invoked only in cases where there exists genuine sexual violence, coercion, or absence of free consent. To convert every sour relationship into an offence of rape not only trivialises the seriousness of the offence but also inflicts upon the accused indelible stigma and grave injustice."

This judgment reinforces that consensual relationships between adults, even those that end badly, cannot be criminalized as rape. The Supreme Court emphasized that rape laws exist to protect against genuine sexual violence and coercion, not to provide legal recourse for failed relationships or personal disputes.

📞 When to Seek Professional Help

👨‍⚖️ Criminal Lawyer Essential For

  • Facing false criminal charges in relationships
  • Quashing FIRs based on consensual relationships
  • Protecting against misuse of criminal laws
  • Appeals in relationship-turned-criminal cases

📝 You Should Understand

  • Difference between consensual sex and rape
  • What constitutes false promise of marriage
  • Your rights in personal relationships
  • When criminal law can be legitimately invoked

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

🌿 LegalEcoSys Mission

Making Supreme Court judgments accessible and actionable for every Indian citizen navigating legal challenges.

This analysis decodes a complex criminal law judgment to help citizens understand the crucial distinction between consensual relationships and criminal offenses. It empowers individuals to recognize when criminal law is being misused and protects the integrity of genuine rape cases.